The New DIIRSP: I like the old better

- By : Parag Patel

…the taxpayer has not failed to report tax.  Old DIIRSP: Before the change, the DIIRSP originally stated: Taxpayers who do not need to use the OVDP or the Streamlined Filing…

Explore the OVDI opt-out option: Argue for Penalty Mitigation

- By : Parag Patel

The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with six examples. See FAQ 51….

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

- By : Parag Patel

…John Doe Summons, e.g., HSBC Summons for account information B. Information submitted by more than 50,000 taxpayers participating in OVDP/OVDI as of January 2015, possibly including your banker, advisor or…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…program (OVDP). If a person has an undeclared overseas account at a foreign bank and has received a letter from their foreign bank they should retain a qualified tax attorney…

Vatican Signs FATCA Agreement

- By : Parag Patel

…under the umbrella of the Offshore Voluntary Disclosure Program (OVDP). Last year, the IRS announced its new streamline program for non-willful taxpayers with lower penalties to make it more appealing…

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

- By : Parag Patel

…offers a welcome option for many taxpayers with undeclared accounts, other ways to address past noncompliance remain viable, including the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International…

Correcting Common FBAR Errors

- By : Parag Patel

…iteration of the OVDP program is intended to help those taxpayers who knowingly violated the tax laws to come back into compliance and avoid criminal prosecution. In general, this program…

How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

- By : Parag Patel

…a warning. While the streamlined program offers a welcome option for many taxpayers with undeclared accounts, other ways to address past noncompliance remain viable, including the OVDP program and Delinquent…

IRS delinquent FBAR submission procedure

- By : Parag Patel

…counsel in filing the delinquent FBAR submission procedure. Delinquent FBAR Submission Procedures Taxpayers who do not need to use either the OVDP or the Streamlined Filing Compliance Procedures to file…

Another HSBC Customer Likely Going to Jail

- By : Parag Patel

…should persuade offshore accountholders who cannot decide whether to disclose past foreign account noncompliance to the IRS via the IRS Offshore Voluntary Disclosure Program (OVDP), for protection against civil (and…

IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements

- By : Parag Patel

…of special opportunities to comply with the U.S. tax system and resolve their tax obligations. At the beginning of 2012, the IRS reopened the Offshore Voluntary Disclosure Program (OVDP), which…

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

- By : Parag Patel

…bank supports you in this step and will assist you in this process by gathering the information and documents in the bank’s possession that are required by the OVDP,” in…

Citizenship renunciation fee increases as American expatriates flee FATCA

- By : Parag Patel

OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. Sources Wall Street Journal Money News Forbes Federal Register (PDF file) US State Department STEP News…

Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.

- By : Parag Patel

…HSBC (and other fearful foreign bank customers) have since successfully entered the 2011 OVDI and 2012 OVDP programs to avoid further civil or criminal complications. US citizens and residents must…